APPENDIX C
REVIEW OF ALTERNATIVES SELECTED IN EPA'S SEPTEMBER 30, 1985 RECORD OF DECISION
FOR REMEDIATION OF THE LIPARI LANDFILL
RECORD OF DECISION DATED SEPTEMBER 30- 1985 (ROD III
<*> CM I in CM 0 1 10 o
273231 332 iiniiinii
1 *
0^^ RECORD OF DECISION REMEDIAL ALTERNATIVE SELECTION
cci 11.. ,
l/(,7 Fc.jy ;~»>Vi:y
Site
&2] Lipari Landfill, Mantua Township, New Jersey n^^iimpnts Reviewed I an basing my decision primarily on JJ® remedial SM^o^h^" Ml site:
Treatability Study of Contaminated Groundwater from the " uepl" liidfill, R®dian Corporation, - On-Site Feasibility Study for Lipari Landfill, Camp, Dresser & McKee, Inc.,
- On-Site Hyd rogeologleal Remedial Investigation of Lipari Landfill, Camp, Dresser & McKee, Inc.,
- Summary of Remedial Alternative selection. Lipari Undflll.
- Staff summaries and recommendations, - Responaiveneas Summary for the Lipari Landfill.
nescription selected Remedy
,. Install 9round"®^if J^for^eiaJeJitg^jrflushing within the containment system of the system.
2. Pump and treat the ^"^^^^hJs^^elevJtionhof £pprox-containment system nntil it (Upper Cohansey). imately 100 feet above "e"rS®®,^ted leachate is on-site The treatment P*e*®re?c* to the poTW. Implementation 'pretreatment and discharg state of New Jersey is dependent on timely appro ' . not provided, the and the local POW. « »un!j*^I°ddla=h«°,ed to nearby XSSTfdZ o^transported'of£-site for treatment at a permitted hazardous waste facility.
3 install and monitor groundwater well, downgr.dl.nt of the i"i within the Rirkwood Aquifer. /
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4. Flush the containment system to cleanse the encapsulated material of water-borne contaminants. This operation will be coordinated with any off-site remedial action, especially with regard to leachate treatment. An estimated 15 years is required to remove 90% of the water-borne contaminants from the groundwater within the containment system. Throughout the operation, regular evaluations will be made to determine the effectiveness of the flushing program; as well as, the need to continue this program or to take other actions.
5. The flushing operation will achieve the reduction of contaminants in the containment system to the limits of its technology. Should it be determined that the resulting groundwater does not meet applicable standards, then pumping and treatment of the groundwater/leachate from within the containment system will be maintained, after the flushing operation is terminated, to control lower water levels within the system than outside.
Declarations Consistent with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR Part 300), 1 have determined that flushing the containment system and monitoring the Kirkwood Aquifer groundwater constitute the selected Phase II on-site remedial alternative for the Lipari Landfill site. The State of New Jersey has been consulted and agrees with the proposed remedy. A determination of potential Phase II off-site remedial actions to mitigate potentially contaminated off-site areas will be made in the near future. The action being taken is appropriate when balanced against the availability of Trust Fund monies for use at other sites. In addition, flushing the containment system and monitoring of the Kirkwood Aquifer are cost-effective, implementable and technically sound when compared to other remedial action alternatives, and are necessary and adequate to protect public health, welfare and the environment.
Date Regional Administrator
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gummarv of Remedial Alternative Selection Lipari Landfill Site
Mantua Township, New Jersey
site Location and Description
The Lipari Landfill JlM" S7
MS were^used fo^hazardoua waste landfillin9 activities. ?^ndfill is P^^ggm^egtYof"Glas3boro°State Coileqe. Route 322 and 1.5 mile *.a the northeast border of ?K!teraiS ap"e fnd"palch orchards sorround the east and southern border.
as- i.ss r:.rrs.r:;:: a. autsiias" concerning the site and its surrounding area.
SS^SSSjansir-
Flowing plsf^he'eastern and ^^heastern b«J«s site, Chestnut Branch di8C!"?*" fcJ on Like, Chestnut 1000 feet downstream. Continuing discharges into the Delaware^River J/^ .iies -t^est^the
western edge of the landfill and discharges into Chestnut Branch north of the landfill.
Parklands surrounding Alyc°? JjS^tivitits'on the'lake"""1 itsel7have^bee banned*^, the Gloucester Count, health Department.
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SITB HISTORY
Disposal Operations The site was purchased in 1958 by Nick Lipari for useasa sand-and-gravel pit. Approximately six acres of the site were utilized for this'operation. Trenches excavated to remove the sand and gravel were backfilled with municipal refuse, household wastes, liquid and se™i""solid1c!'®mi"i(. * ong wastes, and other industrial wastes. The nonsalable portions of the excavated sands and gravels were used to c?ver the disposed wastes. Liquid wastes were dumped into the landfill from 1958 to 1969 and solid wastes were disposed of there until Hay T?71, when the site was closed by the New Jersey Solid Waste Authority. During this period,!^aldfill0"6 explosion and two fires were reported at the landfill. Although no detailed records were kept, it .h'a J?® Imated that 12,000 cubic yards of sol*d wastes and . aallons of liquid wastes were disposed of at the site. Tne llluTas disposed of at the site are thought to be largely uncontained. The wastes reported to have been d*®P°a®d of include solvents, paint thinners, formaldehyde, paints, phenol and amine wastes, dust-collector residues, resins and ester press cakes. Numerous organic compounds have been identified at the ®*te' mostly in leachate samples. The most noteworhty compound identified is bis (2-chloroethyl) ether, a suspected human carcinogen, found in high concentrations. Other noteworthy compounds include benzene, ethylbenzene, phenol ®nd "J^in Table 1 shows the compounds and their concentrations found in the Lipari Landfill leachate. Table 2 lists the chemicals of concern for the Lipari Landfill. EPA has initiated enforcement action against the following firms who have generated or transported h?*ard°uJ the landfills Rohm and Haas; Owens-Illinois; an Manor Health Care; CBS, Inc; and Marvin Jonas, Inc. Hazardous wastes dumped at the landfill have percolated into the groundwater under the landfill. The wastes have also leached out into the embankments of Rabbit Run and Branch, contaminating the surface waters that ri n into these streams and Alcyon Lake.
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Current Site Status * removal action at the site ^.J«Ll'".ction the U.S. Environmental Protection Agency. The rjmo ^ consisted of the installation o a en ugu9t 1903, a second th. landfill (see Figures 3 and 4). In Jugusch„tiut Branch t^diacourage'th^nearby rS'id'e"^.^^.^, th. contaminated marsh area along the stream.
landfill began on September 7, 1903. A 30 11n Qf bentonite slurry the supervision of the U.S. the site was constructed under the to segregate
Sift density°polyethylene over the .it. t. exclude . - ejst^ a surface also consisted of a passive g rev*getation. Construction o^the^containment system was completed in Hovember of 1934.
EPA determined inthe'932 RODthata •"J^^'^Lbility remedial action should be imP];e™*"|eti t£e second phase of the cbntainment system. At^|__ ^ cont^inated was defined as collection vgte„ TRe~l.mplemenEation groundwater_within the containmentsystem ™erp of thii remedial action was deferred in the learn loc>1 the compatability of the pretre . evaluated. In Publically Owned TreatmentWorks (POTW) was ever a ^S'iStBaSlT.rt the containment system and cap while this evaluation was being done.
in the spring of ''"•^i;"1?°r?.n«CUiro?^hes"unt,Sran?h (Figure 4) to'further restrict access to the contaminated marsh <nr€3<
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REHEDIAL INVESTIGATION ACTIVITIES AND RESULTS on-site Remedial Investigation Activities
instigation, "the landfill and the immediate areas
•surveying the casing elevation of .11 the exiating ground-water monitoring wells. •Slug-testing 26 wells along the interior and exterior circumference of the slurry wall. •Yield-testing all wells greater than 2-inches in diameter, •pump and injection-testing the contained Cohansey Formation,
•pump-testing the Kirkwood Formation. ,
• "SiUtSl liSSia " - [tiea.
on-site Remedial investigation Results The results of these investigation activities indicated the followings
ated groundwater/leachate from the surrounding Cohansey Aquifer. •currently, the net direction of potential seepage jhl wall is inward at the southwest portion of the
day (gpd) are currently seeping through the slurry wail into the upgradient Cohansey Aquifer. •The Cohansey Aquifer is flowing in a northeasterly direction toward the Chestnut Branch. •The hydraulic conductivity of the Kirk-nod ClayieaPPro><-imatelv 1.1 x U "7 centimeters per second (cm/sec). Seepage will continue to flow into the Kirkwood Sands below the Kirkwood Clay Formation •• l®nJ " 5$ef*etUabove Hean
rie«lh'«^- ''lSo"Pd "" CUr""tly seeping into the Kirkwood Clay.
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*The saturation of the entire Kirkwood Clay and the continuous seepage of contaminants into the Kirkwood Sands has not been confirmed by analysis of samples taken of the Kirkwood groundwater.
'The estimated seepage flows are consistent with design predictions and are not attributed to construction deficiencies. •Groundwater flow in the Kirkwood Sands is northeasterly towards Alcyon Lake. •Dewatering of groundwater/leachate from, and injecting clean water into, thl Upper Cohansey portion of the containment system is technically feasible. •Onlv three of the existing wells screened in the Cohansey Formation can be used as extraction or injection wells. •The Lower Cohansey sands are approximately ten times less permeable than the Upper Cohansey sands, making dewatering of the Lower Cohansey technically impracticable.
'Hvdrofracturing of the slurry wall is not probable with a fifteen foot hlad differential across the wall. Channeling of the wall is also not likely. •Assuming that the leachate quality d?«a differ with the samples submitted, all of the privately owned treatment facilities contacted would accept and treat leachate from the Lipari Landfill. •Potential seepage of contaminants to the Cohansey aJd the Kirkwood Aquifers presents an ®n^ron,?e"^that health hazard. Groundwater modeling indicates that bis (2-chloroethyl) ether will persist in the groundwater and migrate to the streams and lake. Eve"tua ootentially compound may attain concentrations considered potentially hazardous to human health. 'The compatability of raw leachate with the treatment systems used at the local POTW has Jeen confirmed in the treatability study. Therefore, pretreated leachate will have no adverse affects oh the POTW treatment process.
•Leachability tests on extracted Lower Cohansey sands demonstrate that the water-transportable contaminants *5* J"*duce by 90% in the leachate after 10 pore volumes have been passed through the sample.
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REHEDIAL ACTION ALTERNATIVES Remedial Action Objectives The 1982 ROD determined that the overall objective of further on-site remedial action is to "improve the reliability'of the containment system." At that time, it was determined that this should be accomplished through installation of groundwater collection wells within the containment system and treatment of this groundwater prior to discharging to the local POTW. During the On-site Remedial Investigation, it was determined that, should no further action be taken to enhance the containment system, two pathways of potential risk to the environment and human health would persist! (1) slow but continuous seepage of contaminants through the slurry wall into the downgradient Cohansey Aquifer and into the nearby surface streams, and eventually into Alcyon Lake; and (2) seepage of contaminants downward through the Kirkwood Clay into the Kirkwood Aquifer, which flows towards Alcyon Lake. Therefore, to meet the overall objective (as definedin the 1982 ROD) of improving the reliability of the contaminant system, minimizing or eliminating the flow of contaminants from these two pathways is essential. This could be achieved in any of several ways: (1) Complete removal of the source of contaminants; (2) Reversal of the hydraulic gradient across the slurry wall,
causing all potential flow to be inward; (3) Capture of the contaminants entering the Kirkwood Aquifer; (4) Solubilization and extraction of contaminants from the
landfill.
Remedial Alternative Options According to the draft National Oil and Hazardous Substances Contingency Plan (NCP) and current policy, five categories of remedial alternatives must be considered when evaluating candidate remedial options. These categories are: I. Off-site storage, destruction, treatment or secure disposal
of hazardous substances at a facility approved under the Resource Conservation and Recovery Act (RCRA). Such a facility must also be in compliance with all other applicable EPA standards (e.g.. Clean Hater Act, Clean Air Act, Toxic Substances Control Act);
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II.
III.
IV.
sssatisii?£.;»'.u«s aaas . and advisories; Mt.rn.tl.es that exceed .11 applicable " relevant Federal public health and environmental standards, guidances, and advisories; ait-prnatives that meet the CERCLA goals of preventing or sibstiScSs andSprotectfhuman SellthiaSd°thea^vi?onment, Iftiollt attain the applicable cr relevant standards,
V. No Action. Potential on-site remedial o^thes^options and their related HCP cate9orles are discussed below: • 1. complete Removal (Category I)
aM&sssriK!;-in the most cost-effective manner.
a fglUtT als^be insistent
' ^Sd'S'SlSa-iMiS Serial, -"clvltfofw"ld
release of volatile organic compounds to tne en
2. Enhanced Containment (Category IV) 'This option consists of dewatering the ssahas sas a: saasa si=
the slurry wall is into the system, thus precluding y additional off-site~m!gration of *ontJinment system groundwater/leachate pumped from the would be treated and disposed of in a cost eiK« ma nnaT
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Th e Enhanced Containment Option with on-site pretreatment and discharge to the local POTW was the second phase remedial action as described in the 1982 ROD.
3. Flushing of the Encapsulation System (Cleanup) (Category II, III or IV depending on the level of treatment achieved) Under this option, an attempt would be made to clean the site by flushing the contaminants out of the soils and debris in the encapsulation system. Flushing is accomplished by injecting clean water into the system, saturating the system and "flushing" the contaminants from the soils and debris. The now-contaminated water would be treated and disposed. Different alternatives to this option consist of how flushing would be carried out; that is, whether it would be a continuous or batch-type operation. Other alternatives to this option consider whether the flushing water should be clean upgradient groundwater, public water, or treated post-flushing water pumped from the site. Should treated post-flushing water not be used for reinjection, it would have to be disposed of in a cost-effective manner.
4. No Action (Category V) Under this option, the site would be left in its present condition and a groundwater monitoring program would be implemented.
Components of the Remedial Action Options The remedial action options described above can be broken down into the following components:
'Disposal 'Eeachate collection 'Treatment of various waste streams
A variety of technologies exist that could make up these components (Table 3). These technologies were subjected to a technical, environmental, public health, institutional, 'iQ cost screening respectively. Those technologies that passed this screening (Table 4) were integrated into candidate remedial alternatives and evaluated in detail.
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Groundwater modeling revealed that the bulk of future potential contamination from the landfill to the environment would be through the Kirkwood Clay into the Kirkwood Aquifer. Therefore, capturing the leachate entering the Kirkwood Aquifer by pumping the aquifer became a component of candidate remedial alternatives. Candidate Remedial Alternatives Seven candidate remedial alternatives (Table 5) were evaluated in detail. Each of these alternatives have subalternatives which were in turn evaluated. The following are descriptions and evaluations of all alternatives, and subalternatives. Alternative 1 - Complete Removal Dewater the containment system and treat and dispose of the collected leachate. Remove the existing cap, excavate the contaminated soil, refuse and miscellaneous bulk material, and transport this material to a RCRA-permitted secure landfill that meets EPA's Off-site Policy for CERCLA wastes. Fill with clean material, compact, grade to approximate local conditions and seed. Excavation would have to be carried out within an enclosure to minimize the release of volatile organic compounds to the environment. The subalternatives represent alternate means of treating and disposing of the leachate and are as follows: (a) Off-site Treatment at a Privately-Owned Treatment Storage
and Disposal Facility. Store the leachate on-site in a holding tank sized to contain a three-day flow. Transfer the leachate from the holding tank to a series of tank trucks using a 5-day work week schedule. Transport the leachate to an off-site facility for treatment and disposal.
(b) On-site Pretreatment and Discharge to the Local POTW
An on-site pretreatment facility will have to comply with the pretreatment requirements of both the local POTW and the NJDEP. Therefore, an on-site pretreatment facility at Lipari would include: a flow equilization basin, a precipitation/flocculation/sediraentation reaction system to remove metals and suspended solids, air stripping to remove volatile organics, a filtration/activated carbon adsorption system to remove phenols, and treated leachate holding tanks to permit monitoring and to ensure discharge acceptability by the POTW.
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Sludge generated will be disposed at a permitted off-site facility. Air emissions will be controlled by the use of vapor-phase carbon units.
(c) On-site Treatment and Discharge to Chestnut Branch Discharge to Chestnut Branch would require the removal of solids, BOD, COD, and TOC, as well as reduction of priority pollutants in compliance with NJDEP's discharge criteria for Chestnut Branch. Two alternate technologies could be used to meet these criteria, the PACT (powdered activated-carbon treatment) process or a physical/chemical treatment process. Waste streams generated by either facility would be treated on-site or disposed of at an appropriately permitted facility.
Under the complete removal alternative, the source of the contamination would be removed by excavation, thereby achieving the goals of site remediation. However, major risks are associated with the implementation of this alternative. This alternative is the most difficult to implement because of the problems associated with excavation withi'n a controlled environment. In addition, by removing the existing cap from the containment system, the trapped volatile organics would probably be released. Even though excavation would be done within an enclosure, the potential for release into the atmosphere and the impacts on the local community are expected to be significant. Excavating, handling, and transporting approximately 864,000 cubic yards (CY) of hazardous material pose numerous hazards. Exposed wastes would constitute an extreme direct—contact hazard to on-site workers, and would create a hazardous atmosphere within the excavation structure. Therefore, this the least desirable of any of the alternatives with regards to worker safety. Because of the large number of trucks used to transport the hazardous material to a RCRA-permitted facility, additional safety hazards exist under this alternative in the form of potential traffic accidents and hazardous waste spills. It is EPA's policy to pursue response actions that use treatment, reuse or recycling over land disposal to the greatest extent praticable consistent with CERCLA requirements for cost-effective remedial actions. Because of the limited land disposal facilities available and the inherent problems with land disposal, it is EPA's policy to use land disposal only when other alternatives are impracticable or do not sufficiently safeguard public health and the environment.
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Finally, this alternative has the highest cost of all alternatives considered. Alternative 2 - No Action but Pump the Kirkwood Sands (Enhanced
Containment) Leave the encapsulation system in its present state but pump the Kirkwood Sands beneath the site. Utilize four wells to caDture vertical seepage from the containment system which percolates through the Kirkwood Clay into the underlying Kirkwood Sands. Treat this collected leachate by one of three subalternatives:
(a) Off-site Treatment at a Privately Owned Treatment Storage or Disposal Facility;
(b) On-site Pretreatment and Discharge to the Local POTW; (c) On-site Treatment and Discharge to Chestnut Branch.
The concept for this alternative is that once the entire thickness of the Kirkwood Clay is saturated with contaminated groundwater/leachate, the bulk of the contaminants leaving the site would be through this pathway into the Kirkwood Aquifer. Therefore, the goals of the second phase remedial action would be partially met through the implementation of this alternative. While the potential remains for seepage of contaminants through the slurry wall into the Cohansey Aquifer -and ultimately into the streams and lake remains under this alternative, the potential for seepage of contaminants into the Kirkwood Aquifer would be removed. It would take approximately 4 years for the groundwater in the containment system to naturally reach a steady state at the 107 foot elevation. At this elevation, approximately 150 gpd would seep through the slurry wall and approximately 1500 gpd would seep vertically through the Kirkwood Clay. Seepage of contaminants through the slurry wall J™"**®1?*® applicable groundwater criteria and pose a "a* *®„ human health. As noted above, seepage through the slurry wal1 eventually reaches the surrounding streams and lake. Tne estimated concentration of bis (2-chloroethyl) ether in t e lake due to potential slurry wall seepage would be 0.13ppb ppb which would pose a health risk. Disregarding this risk, this alternative is technically feasible and implementable. It is unknown how long it would take for the contaminant concentrations found in the groundwater in the containment ®yat*" and in the Kirkwood Aquifer to be reduced to levels that meet all relevant and applicable groundwater standards. However,
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it Is estimated that it would take 35 years to "J"®6 . contaminant concentrations of the groundwater in the contain ment system to 10% of the initial Likewise, it is estimated that it would also take 35 years for the contaminant concentrations f^ IJlntrltion ^sa^Y^h^onWUmiStlysSam." This contaminant^ sr sM rtS SiVarco.t.i-.nt =y,tM.
Due to these unknowns, the actual life *.he iven cannot be determined at this time. The time «B®ti™ates given *"h":=tr.i°nr.c o°rnt'hnia. "£»&. .m *
II alternative concentration limits.
^•iju-irss :;;.i::.si~us:u.:':u JSyijp!™
S5S4SSBK-£5s^^f-process would need to be performed for each alternative. alternative 3 - Dewater the Encapsulation System (Enhanced
" Containment)
b-?'mraSSed?^uc:rntKyc^rcUrieiSint.thb? s!W following subalternatives:
(a) Off-site Treatment at a Privately Owned Treatment, Storage and Disposal Facility;
(b) On-site Pretreatment and Discharge to the Local POTWj
(c) On-site Treatment and Discharge to Chestnut Branch.
Dewatering the Upper Cohansey within the containment system
outside level, the hydraulic gradient across the slurry wall would be inward.
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Other benefits to dewatering the containment system include a decrease in the vertical seepage through the Kirkwood Clay due to the decrease of driving head, and a decrease of potential degradation of the slurry wall due to the decrease of the wetted surface area. As indicated before. Alternative 3(b) was the Phase II remedial action identified in the previous Lipari ROD to achieve the objective of improving the reliability of the containment system. However, there is a health risk associated with this alternative. During the Phase II on-site remedial investigation and feasibility study, it was found that the majority of the potential seepage out of the containment system would be through the Kirkwood Clay. Because the Kirkwood Aquifer is believed to discharge to Alcyon Lake, this potential seepage poses an environmental and public health risk at the lake* Modeling results show that bis (2-chloroethyl) ether would persist in the lake in concentrations exceeding federal Water Quality Criteria (0.41 vs. 0.03 ppb). Disgregarding this risk, this alternative is technically feasible and implementable. ' An estimated 28 years would be required to reduce the contaminant concentrations of the groundwater in the containment system to 10 percent of the initial concentrations. As stated above, this concentration reduction phenomenon is expected to occur because of natural flushing of the material in contact with the groundwater. Under this alternative, care would need to be exercised in deciding when to terminate the operation. Should the contaminant concentration be reduced enough for the responsible agencies to decide to terminate the operation of this alternative, it is likely that the groundwater levels would rise and saturate materials that had been dry during the operation of the facility. This resaturation of materials could potentially cause leaching of chemicals, again threatening the environment and human health.
Alternative 4 - Dewater the Encapsulation System and Pump the Kirkwood Sands (Enhanced Containment)
Dewater the Upper Cohansey formation within the containment system. In addition, pump and collect the vertical seepage from the encapsulation into the Kirkwood Sands beneath the site. Under this scenario, two different waste streams would be collected (leachate/groundwa».er from the Cohansey within the encapsulation and leachate/groundwater in the Kirkwood Aquifer). Treat both waste streams using one or more of the following subalternatives:
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off-site Treatment at a Privately Owned Treatment storage and Disposal Pacllltyi
. J nischarqe to the Local POTW; (b) On-site pretreatment and Discnarg ,c) on-site Treatment and Discharge to Chestnut Branch.
Because this alternativj, goes b e y o n d Alternative Umecta the objective of theuphasevH"„t svsteni. In addition, this the reliability of containmentjyste^^ g inq from the alternative action mit 9 in«.0 the Kirkwood Aquifer, possible s e e p a g e of leachate ^ contamination of the Therefore, should the P® this alternative is considered superior t^Alternative 3 on'.n environmental/public health basis. This alternative is considered technically feasible and implementable.
.a .amiirsd for the contaminant An estimated 23 years t^q£0 be reduced.to 10% of the concentrations of the 9 addition, an estimated initial concentrations fou . contamlnant concentrations 25 years wouid he required 1% of the initial concentrations observed1in'the containment system.
as in Alternative,3, she,du^o^ha* terminated, leaching o c _ i ugj~ kept artificially dry. ^^"^afl^^ySUSSil woSld again threaten the environment and human health. Alternative 5 - Flush the Encapsulation System (Cleanup)
Dewater the Upper Coha"®*yon^^completedt"^-?ill"the contain-system. °nce ^"r". Extract the now-contaminated ment system with clean^wa<c hil injecting clean water from the out» the contaminants from water into the system t hig operation until the the soils and debris. svstem meets all relevant and water within the co"*al™tieria or until concentrations are
clean^ flushing SS"" d lea°hata " " constitutes the following subalternati .
(a) Treat the extracted leachate/flushing water on-site using either a PACT process train or a physical/chemical treatment train. Re-inject the treated e£fluent for flushing water;
(b) Pretreat the extracted leachate/flushing water on-site and discharge to the local POTH. Use either upgradient groundwater or water from local public supply as clean water;
(c) Treat the extracted leachate/flushing water on-site and discharge to Chestnut Branch;
(d) Proceed as in 5(a), but omit the initial dewatering of the system.
This alternative partially meets the objective of the Phase 11 remedial action of ensuring the reliability of the containment system. This alternative is an active attempt t«o remove the water-borne contaminants in the containment system. However, there are two potential risks involved:
1. The water level inside the containment system will be kept higher than the groundwater level in the north, east, and southeast side of the site, resulting in a potential flow out of the containment system in these areas. This outward flow potential could result in additional contamination of the Cohansey Aquifer, the marsh area, the surrounding streams, and Alcyon Lake.
2. There is no provision for capture of potential seepage to the Kirkwood Aquifer. Risks associated with this condition have been defined above.
The potential contamination of the streams and Alcyon Lake due to potential flow through the slurry wall could be mitigated under a seepage collection system, which may be developed under the authorization of a subsequent Lipari ROD. As stated previously, an Off-site Remedial Investigation and Feasibility Study (RI/FS) is presently being prepared for the Lipari Landfill. This Off-site RI/FS will look at the need for and alternatives to remedial action for the off-site areab. These off-site areas consist of the marsh area, the streams surrounding the site and Alcyon Lake. Disregarding these risks, this alternative is technically feasible and implementable.
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The main advantage of this »"«n.tlv. U /^EEEr-Eorn. cleanse the material 'j" «1«-E«necontaminants contaminant. The remova £ Teaching from the
E:dtue":wtS;E"he r ^ r:t«EeEhrtEEEiErtiaoE f^EEEsfE! f lushing^peration, .h-.it. presence would be limited to a monitoring program. The technical components of I*i»e»"«^t^;in£g?E"aCti0n and injection of ^rodndw®Jer, ar P limited by The extent of reduction of contaminants JJJJfatory goil ihS bilitv^tes^conducted with soils from Lipari, it is leachability test conauv.u . rtable contaminants "nCEEdrEEEEe"fr« til lEEEEaEETi?h the passing of ,0 pore volumes of water.
Nevertheless, the 'iEL'EE.'ElEf of future contaminants ent | while it is unknown when makes this alternate abb*a . *h groUndwater within the the contaminant concentration in the groun^ relevant containment system will me alternative, it has been standards and statutes under this 90% of the estimated that it would take!J years to^e^ gystem> water-borne c;n^?gnaJternative would have to be determined Termination of this.^^h all other alternatives, the above
ui fS alternative comparison and cost estimating purposes only. Alternative 6 - Flush the Encapsulation System and Pump the Alternative _ Rirkwood Sands (cleanup)
Under this scenario, subaJtern^a^eJhjought5(dV)9except that coincide with subalternatives 5ta}pumping of the Alternative 6 '^alternatives uould include pempin,^ Kirkwood Sands to draw potential vertical * containment system.
while this alternative addresses the^potential ®?"£Eoodat^0n
rroEhn «r°tbeAotUer cEncerL U(|- S ST" of Alternative 5 are tbe.sa"!®: " the water-borne contaminants ?EEi"'atEeedstyiteemrllairyear. as compared to 9 years for Alternative 5.
Alternative 7 - No Action Under this option, the site would be left in its present condition and a groundwater monitoring program would be i m p l e m e n t e d . I n t h i s p r o g r a m , w a t e r l e v e l m e a s u ™ u l d be taken in all wells on a regular basis. In this manner, differential head conditions could be monitored that would lidiclte the direction of groundwater flow across the containment wall In addition, all wells screened within the Kirkwood Formation*and all paired Cohansey wells would be sampled on a quarterly basis. These samples would be analyzed quarterly Torindicator pollutants and annually for priority pollutants to assess changes in any seepage conditions from the svstem. In this manner, the extent and nature of any migrati of contaminants out of the containment system would be monitored and the need for any future remedial action could be planned accordingly. This alternative does not meet the objective of «the Phase II reiedtaJ aSain to improve the reliability of the containment system. In addition, the groundwater within the containment system does not meet any of the relevent and applicable groundwater criteria. Modeling has determined that continued ®®eP^ out of the^ containment system, even at the estimated potentially s rate, poses a threat to the environment and human health. Concentrations of chemicals of concern, specifically bi3 * . rhioroethvl1 ether, a suspected human carcinogen, would P®r S • potential threat to human health (1.2 ppb)
Alternative 8 - Batch Flush the Containment System (Cleanup) 5 and
and 6, This alternative is substantially similar to Alternatives 6, except in the mode of operation. In Alternatives , once the containment system is i!||ousaid the dewatering-reinjection operation would be continuous and concurrent. in contrast, under Alternative 8, flushing would be a batch-tvoe oDeration. That is, the dewatering and the injection operations would not be done at the same time, but in s^nce, Under this system, certain problems perceived with flu^"9 should be mitigated. Vnde%th%CJntinoo?lntial e!is?s fo^ described for Alternatives 5 and 6, a potential exists ioi short-circuiting - a phenomenon in which water seeks the path of least resistance. Channels between injection wells and extraction wells can develop when abort-cl.rcuitxng oceurs^ allowing potential pockets of contaminants th,it i1r®*a. unflushed. This phenomenon would be expected to occur
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LiDari because of the heterogeneous makeup of the landfill and the varying compaction of layers. It is believed short-circuiting could be overcome by completely draining a re-saturating the system consecutively. An estimated 15 years would be required to flush 90% of the water-soluble contaminants from the syste™' «sS,a£?n!i : longer than the estimates for the other flushing
alternatives. However, this mode of operation is expecte remove the contaminants more effectively.
Variations to Alternative 8 are iJ«ntic®1llJ® considerations^iscussed "under "the other flushing alternatives hold true for Alternative 8. Therefore, this alternative is considered technically superior to both Alternatives 5 and 6.
" dlrSSI» tl^Il.ans^the^site'so^that^should^th^containment the rise in groundwater within the system and
SI resi?uriaon If the slii and debris would noV cause future off-site contamination. Therefore, after a successful flushing operation, long-term involvement would be limited to a monitoring program. Evaluation of Subalternatives for Leachate Treatment Process and Ultimate Disposal Moat of the alternatives discussed above showed subalternatives which varied by their treatment process and ultimate discharge locations* Below is a discussioS of these subalternatives:
(a) Off-Site Treatment at a Privately Owned Treatment, Storage and Disposal Facility. This subalternative is .technically feasib1*' *^"table and poses minimum risks. There are several P[^aJ®ly owned treatment, storage and disposal facilities in the area that would accept Lipari's wastes for treatment and disposal. For this option to be implemented, th $<£151! facility's c o m p l i a n c e withallenviconmental laws would have to be ensured. Two dJsad^a"^®S t0 this subalternative exist: (1) risk of ent-worth traffic and spill accidents, and (2) a high present wortn c^lt Holever, use of an off-site treatment facility for ; short-term operation - e.g. initial watering of the containment system - may be competitive short-term subalternatives.
352
-21-
b) On-site Pretreatment and Discharge to the Local POTW. The pretreatment process train *3 necessary to comply with the local POTW's pretreatment [e9nlatf :i£xS?niti« is feasible, poses *"d
has the I""',?"5™';"" the implementation o^thi^sobalternative'wiil be the most diificult^of^the leachate disposal subalternative J. , choice of
limitations for the local POTW. (C) on-site Treatment and Discharge to Chestnut Branch
dUcha^ o^contaminant^into Chestnut Branch and Alcyon Lake. Two treatment processes were investigated for this sub-aThprnative> the PACT process and a physical/chemical
h^hlu/anht fahe Jfthe'ellnSe" is'discharged health risk at this leachate disposal option
JerseyUt PnSf stSdiefl™ Shese treatment processes may be required to refine treatment efficiencies.
, indicated above except: for»°st
ivironmentally-sound -^ tarnarive for le.chat. traatman^ ,d disposal ;0^C AS «cS!lor tJs purposes id discharge it to the loca .. tiveg it was assumed t comparing the eight major a^®™t 7 th , alternatives would lat the leachate/groundwater for all th ! alternate » treated at the local POTW.
353
-22-
Comparlson nf Alternatives
Table 8 identifies the eight »«hilcliren"i%^nt^°r„d and summarizes the costs and the ;®^n^ch'alternative. institutional factors ®sso _ bv which the recommended SLiisuiris ss:s1ir-!usSdhE.ai:
„ discussed .hcte.Jhe^c-Action rf^"'
Landfill* The Ptf^if'^^^^tens^thrin^rlnSnJ'.nd ssinhh^trntnfcas 15rXj. found in the lake at levels of 1.2 estimated to be The life of the e"caJ®Vga^°2cted life could be shortened due 30 y!ar^* HafrIon'effect of the chemicals in the containment to the de9radati°n effec containment system be system. should eff(ect environment and public health lltirt increased^ therefore, Alternative 7 (No Actron, was determined not to be appropriate.
" t h e ot"verdth:fsohu p:ftS:'co a t!on K0::1 4"" threat tt th. environment and thlTIttirnaJi.e risks associated "^h the imp:lem<8 large-scale operation and the inherent I' "Sir factors dis-makes this alternative impr !j bbe high cost of the favor the Complete R**°va\, f "^^llioS fo? the next most alternative C$288 million vs. $10.2 mil:Lion^o RCRA_permifcted costly a^-te^nat ]ja2nd would accept approximately 864,000 cy irhaza'rdoSs rria
Lipari SSiBl.
The two major groups of ^"""^I'^eeed^ontt'lnrntn't-'and what have been categorized as the Enhanced ^rnafcives have ^^^sub^er^Ives1^ .^without the accompanying pumping of the Kirkwood Aquifer.
in the through^the'Klrkwoo^Cla^int^the a t'hreat to th,- " "he
public health because of the resultant conce iandfill
fn lc n r e a£ 5 SSjfe.i5- ~ nsM.S'.is'S-thr su-j.C^-ur^-nt, «h«erved*in%he%Bkwood Aquifer (under ?he landfill only,
-23-
the°reeult of a plst'.lnjuior euent and .ay not be continuing.
To protect the ®^e^Kirkwood°Aquifer Should be under-continuous seepage into known whether the Kirkwood Clay°is i^SSSftTJ.12.a2K' £ ren tro JhU actio determine whether seepage aualitv of the Kirkwood Aquifer installed to ««Jh.r .onitor data confirm the above downgradient of the landfill. Should tne « criteria, and the groundwater exceed applicable .nfl'reie ge flnd treatment^o^thi^g^oundwater/ leachate would be warranted.
The -Enhanced Containment" alternative J«t the objecti.e^f the Phase II R®«nedial Artio" aa of the
containment*^ stem. With Howe ve r?* the r^are^several^isad vantages to these alternatives:
( 1 1 T h e le n o t h o f t i m e t h e en h a n c e d - c o n t a i n m e n t ( U Is likely to be operating is estimated to be 23 to
28 years and potentially longere (2) The source of the contamination remains
S i n c e the containment system has been dewatered,
Isfssssgisi&s °hbrK^arto^rriiLtLInnrn ^ n^ f refucti0„
would occur through the dewatering operation. til Future seepage of contaminants from the landfill is 1 possible^ Once implemented, should the operation
of the enhanced-containment operation cease, th water level within the containment system will araduallv rise to the 107-feet MSL elevation. Tie level may rise higher, depending on the de^®® f POtretin1wtreradiae-0inw0ifllthres8a SM oI inated
Th? ! ia(Li° "f'ooerrheriVth0,thre9at!ie
355
-24-
The future rl.k. "ontlfisda^h Alternatives could be mJ;,;}9a ® agencies to the existence of SS-EcKt^S SS potential off-eite contamination. The Flushing h|s the Potential for essing^the risks associated with the Enhanced cone;%osts. Therefore, at an incremental in)[®stm®"^ f" Shosen for the Phase II the Fiushing Aiternative ha ndfill. The Flushing Alternative will he ""detail in the following section. Recommended Alternative
a l t«nrUve*OV?heFirti below. The Flushing Alternative meets the »bject £• uS" " remedial action for the Li pari By controlling the reliability of the ?ontainm®"^nesof the encapsulation systen^are^nhanced^^Removing the water-soluble contaminants^^ andmimproves^themoverallSremedial action for Upari.
Using the f l u s h i n g mode described ""^^rco^miTn" take 15 years to flush 90% of the than the estimates from the system. This is 6 to y lternativeg. However, siicemthedAlternative 8 ™odea^v°°n®^ennCriteire!!pectedy to'mitigate til short-circuiting problem, the time differential is not considered significant. While there is the potential for contaminants "seep through the slurry wall Jurin^fesiti remedial action to be developed mitigated through an <0nder the mode of flushing under the current °ff site Rl/ wm increase and operation contemplated, th Therefore, this potential decrease throughout the °P«at1™; r/t ^benefits that could exists only 50 % of the time. The long^ congidered to be wortriirsho^-teL'risks, especially since ,hese risks coul he mitigated,
356
25
The National Contingency Plan states that: "The appropriate extent of remedy (for a remedial action) shall be determined by the lead agency's* selection of a cost-effective remedial alternative which effectively mitigates and minimizes threats to and provides adequate protection of public health, welfare and the environment". The Flushing Alternative meets this requirement. While the Flushing Alternatives show a higher present-worth cost when compared to the Enhanced Containment Alternatives, (see Table 6), they are within the level of accuracy associated with cost estimates developed under an RI/FS. In addition, the Enhanced Containment costs shown do not include the possible need for replacement of the slurry wall. When this cost is included ($2.1 million), the present worth costs of the respective alternatives are more comparable. The added benefits of removing the water-soluble contaminants, and removing the potential future environmental and public health risks, are worth the added cost. EPA's CERCLA Off-site Policy discusses the Agency's preference for treatment, reuse or recycling of materials.* This policy states: "When developing remedial alternatives, treatment, reuse or recycling must be considered.... Detailed analysis of these alternatives should include considerations of long-term effectiveness of treatment and comparative long and short term costs of treatment as compared to other alternatives". Flushing of the Lipari Landfill is considered treatment of the contaminants within the system. The Agency's position is that the benefits of cleansing the containment system of water-soluble contaminants justifies the additional cost relative to enhanced containment. While the actual reduction in contaminants during the flushing operation is unknown, studies on Lower Cohansey Sands from the Lipari Landfill have shown that 90% of the contaminants in the leaChate can be removed by flushing ten pore volumes of water through a sample. The actual degree of success of removing the contaminants from the landfill will be determined by the technology available and the actual site conditions.
If warranted, the flushing operation at the site could easily move into the "Enhanced Containment" mode. Since the equipment needed for enhanced containment would also be used for flushing, this shift should be relatively simple. The change in operation would lower the operation and maintenance costs of the containment operation. The extra costs already invested in the flushing alternative are the capital costs of the injection wells, injection water facilities and a somewhat
*For the Lipari Landfill, the U.S. Environmental Protection Agency is the lead agency. 357
-26-
larqer groundwater/leachate treatment facility. The capital construction cost differential between the enhanced containment and flushing alternatives is $1 million. However, the P^enti benefits to be derived from the flushing operation have been determined to outweigh this cost differential. To ensure the integrity of the Kirkwood Aquifer, the recommended alternative includes the installation of monitoring welie down gradient of the landfill. Should contaminant concentrations in the aquifer be found to exceed applicable and relevant criteria, the groundwater pumping to capture this contaminatio would be warranted. In summary, flushing was chosen as the recommended alternative because:
1 Ninety percent of the water-transportable contaminants can be Removed from the landfill so that the potential for future seepage of these contaminants is significant y reduced or eliminated.
2 The operating duration of the flushing program at the landfill is estimated to be ten to fifteen years shorter than other alternatives.
As noted above, the need for and identification of ^medial action alternatives for the off-site area are presently being investigated. The on-site recommended alternative may the off-site area because of the potential for seepage th g SI containment system. This impact wlllhav. "be incorporated into the off-site investigation. In additJon, J treatment capacity may be needed as a re"^ °f potential off-site remedial actions. On-site treatment facilities the flushing operation and off-site treatment facilities should be coordinated. Implementation of the on-site alternative should proceed in phases as described below: • install groundwater/leachate extraction and injection
wells within the encapsulation system for dewatering flushing of the system.
• Pump the groundwater/leachate from within the < system until it reaches approximately 100 feet MSL at°ve (i e the top of the Lower Cohansey). The groundwater/ leachate may be treated either on-site prior to discharge to the local POTM or stream, or off-site at a privately owned treatment, storage and disposal facility.
• install and monitor groundwater wells downgradient of the site and screened across the entire thickness of Kirkwood Aquifer.
358
\ \
-27-
* Plush the encapsulation system to attempt to cleanse the encapsulated material of water-borne contaminants. This flushing operation will be coordinated with potential off-site remedial actions. -Throughout the operation,' regular evaluations w£ii be made to determine the effectiveness of the flushing program; as well as, the need to continue this program or the need to take other actions.
The State of New Jersey recommends that Alternative 8 should be implemented as described above. The following listed figure represent a cost estimate for the proposed remedial action. The EPA will beure®Pon®^1® paying 100% of the project design. Cost sharing for project implementation is 90% Federal and 10% State of the cost to implement the remedial action.
cost Summary for the Implementation of the Recommended Alternative
Alternative No. 8b - Flushing t
Remedial Measure Capital 0 & M Present-Worth Comoonent Costs Present-Worth Present Worth K IVTF'IOH
U iS'iijeSK^Sius $688,000 $2,139,600 $2,827,600
2. Pump, treat and /' dispose of one pore 340,000^ 340,000t volume '
3. Install Kirkwood 210,800 groundwater wells 122,500 88,300
4. Monitor Kirkwood 179,500 179,500 Aquifer
5. Monitor wells within 775,800 the containment system 775,800
6. Operate and Maintain Treatment and A *71 *nn* Flushing System 2,653,500* 1,510,000* 4,571,500
TOTAL $3,464,000* $5,441,200* $8,905,200*
t Cost is for on-site pretreatment with permanent on-site treatment system and discharge to local POTW.
* Estimates based on flushing only. Changes in these costs will be dependent upon the off-site/on-site treatment systems ^ ultimately designed.
/
-28-
Consistencv With Other Environmental Lawa The recommended alternative for the Lipari Landfill Bite includes extraction and disposal of groundwater/leachate. The groundwater/leachate will be treated on-site prior to discharge to the local POTW or to Chestnut Branch, °r.wi^.^e transported off-site and treated at a RCRA-permitted facility. Under any scenario, this alternative meets all the regulatory criteria. The Draft National Contingency Plan states that "Federal, State and local public health or environmental permits are not required for Federally financed remedial action... However, remedial actions that involve storage, treatment °r d*sp°®a*. of hazardous substances, pollutants or contaminants at off-site facilities shall involve only such off-site facilities that are operating under appropriate Federal or State permits or authorizations." This requirement will be met for the remedial action taken at the Lipari Landfill. An assessment was made as to whether the groundwater in the encapsulation system would meet all relevant and applicable standards after completion of the remedial action. Thirteen "indicator" chemicals were chosen to make this assessment. Since it is impossible to determine how clean «roundwar would be at a given time, a gross evaluation was made to see whether 99% removal of contaminants would meet the relevant and applicable standards. Table 9 shows the results of this assessment. As can be seen from this table, if 99% removal of the contaminants was achieved, the only "J*"*®**!?* HAS SNARLS met are the 1-day EPA SNARLS limits and the 1-day IHAS SNARLS. The RCRA Part 264 groundwater standards could also be met, depending on the initial concentration of chromium assumed in the leachate. Even at 99.9% removal of theJ°nta!"*na"* _ concentration (if this could ever be achieved), the •e"^re array of potential remediation criteria could not be met. Sipce it is unlikely that the technology available would exceed 99.9% removal efficiency, the groundwater in the landfill will probably never meet'-allrapptica&le-er-feleVant standards. As stated earlier, the requlatory ®9encies will make regular evaluations of the effectiveness of the/e;®d*®* .®?**° determine the need for alternate concentration limits.
360
-29
Operable Units The overall Lipari Landfill remedial action has been broken into three operable units:
1. Installation of the containment system. (completed) 2. Implementation of Phase II - On-site Remedial Action. 3. Implementation of Phase II - Off-site Remedial Action.
The subject of this ROD is the implementation of the Phase II on-site Remedial Action.
Extent of Remedy During development of the RI/FS, an analytical procedure which included bench scale laboratory testing, was utilized to simulate the leaching and removal of contaminants from the landfill for different source control alternatives under consideration. In order to compare the cost of different landfill flushing options on a common basis, a standard performance level of 90 % removal was chosen. The analytical procedure is considered as adequate for the comparison of alternatives and is a reasonable application of existing data and knowledge of the site. However, this procedure is based on several assumptions; and the actual rate at which contaminants are flushed from the landfill can not be verified until the actual operation begins. In general, the first flush cycle should remove the greatest mass of contaminants from the landfill. Subsequent flush cycles will yield smaller quantities until eventually the yield from successive flushes will approach a constant value which will be greater than zero for the forseeable future. The level of contaminants which are leached from the landfill at any 9iven time should be directly related to the quality of the leachate which is released to the groundwater. Thus, during the early stages of operation, the ratio of the cost to treat one pore volume (batch volume) to the improvement in leachate quality (ie. difference in total mass removed between successive flushes) will be relatively small. However, with continued operation of the flushing and treatment alternative* this ratio should increase because the cost to treat a pore volume of leachate will be relatively constant but the improvement in leachate quality will approach zero.
361
-30-
A oractical definition of a feasible level of source control
in leachate quality even though small quantities practical may continue to be removed from the landfill. Tnus p
cost for operation. , ,i flushina system there will be sampling
'is:
Ss ^T"s?sSS - -
comrentr.tions are ptojec « a groonaHater cleanup program S^'deX^ed in addition, leachateSfr o mn,the°landfiliewlll not result in a »iolationo£ applicable groundwater and s«f«ce water^standard,s. iXrtiXXS SXS HnJro! system along with "- performance of the chosen groundwater and surface water * The analysis will assess the effectiveness of the dlff. ent r>iaanun efforts to assure coordination and consistency in «-» event that reasonable performance objectives are not being realized in any one of these areas.
Operation and Maintenance Uoon completion of the recommended remedial action, following are the operation and maintenance requirements:
• Monitoring of groundwater elevation and quality in the Cohansey Aquifer;
• Monitoring of groundwater quality in the Kirkwood Aquifer;
• operation and maintenance of the flushing system, including pumping and treatment facilities.
362
-31-
Date Future Actions
Schedule - Amend State Superfund Contract ^cERCt^or'funding - Obligate Funds for . the state Qf New
Remedial Design Jersey (October 1985) - Initiate Design - Complete Design - Complete Phase "^;®i£SDRI/FS Sa?ch^98686 - Issue Phase II Off site rud - initiate Design January 1987 - Complete Design
Community Relations A public information "jeting was lent to all pitman Borough Hall* !! rieH* «»rties as outlined in the
regarding the On-site and Off-site RI/FS.
Another public meeting ^^^^^SrunL^tkl^by'EPA'T™ B o r o u g h H a l l t o d i s c u s s t h • w o r k t o ^ u n i a e r ^ y ^ consultant as part of the RI/FS. notify them of the local officials and SJElitllJ pwW^ «» overview mfethe9actlonshtal<enew"dite under the Superfund program and S!s ssefin"Ie"il thj.RI/FS lor npiri:edroSll«5Ss°thi"%re«ntation, a question and answer session was conducted.
. c * Ape PPA transmitted copies of the draft Pinal °n Aupst 5, 1985, EPA transmltte^ LandfiU to the On-site Feasibility Reporc amrtinci the public comment Pitman Environmental Commissions starting t. p ..his narTJS The Pitman Environmental Commission placed this period. Tne % nnhiic review. Letters were sent by 3?jBH2ig5£ sssrstcrsjssra the public comment period. A subsequent public meeting «» »»" ™/H"!UJUig"ioM Pitman Borough Ball to discuss the . those b e i n^undertaken for"the off-site portion, and the remedial
363
-32-
parties to notify them of the meetin?. BP* ofo£f_ their consultant presented the preliminary iina* y lt
3SE?Ss®«S"=£3fr raised by the public. Responses to the written comments have ]*JJ •ddJ£j;eSe£i|iiSd »wvsr>hori Dpenonsiv6nass Summ&ry• In addition, information regarding the Community Relations Program is included in the attached Responsiveness Summary.
Enforcement . loo? » settlement was reached with . Nick Lipari, In August 1982, a sf.tcx®ra®2 a,.* inn Consent Decree.
owner/operator, in the form o potentially Responsible
with EPA. Further »«90ti.tlon,to EPA-BQ iol"?!!. DapsrJment of Justice, and a complaint against ths PRPs has recently been filed.
364
»-» Jllll <l.ii °'/!k t. ioo4 L-±iJBi
(itvlrenaenlel HcieurtMnlt mil Anelyfli Her<l»l9U5
( » )
*oUlUe_Or9inlO "^Hiiultno pi>6|
Acrolein Acrylonltrllo Oeniene Bronofora Cerbon lelreehlorlde Cblorobcnicno Cl»lorodlbro»o«elhene Cliloroelhene 2-Chloroelhyl»lnyl oilier Clilorolorn OlchlorobroaoealHene Olchlorodll luoroaethene 1.1-DlcMoroethene 1.2-01thloroelhene 1.1-Otchloroelhylene 1.2-0lehloropropene |.3-0lchloropropylene tlhylbcntene Methyl broalde Irene 1,2-Olehloroethiiie llhylcne dlbroalde (MO)
3.000
10
12
8
54 5.9«| . 4
I.UUU
4. SOU
<50
<40
40
<50
8,100' <50
420
no 5,900
<4oo no <100 IIU . 2)0 '
<100 ID <100 no <240 no Jto 300
<240 no )60
5.400.<69.000,Sl 10
24. <40 no I.<250 MO 4.400
<400 JM
<400 <400
2.200 <50 <40
110 <50 <50
400 <50 <40
<500
18 41.000
<50 <50
50 2.000
<400
29,000 8.700 J'l
1004
| 630
8.300 44,000
508 25.459
148
619
219 Ml
$ Ul
TABLE 1
LEACHATE CHARACTERISTICS AT LIPARI LANDFILL
Volatile Ormwlct (cont'd)
Hethyl chloride Methylene chloride 1,1,2,2-letrechloroethiiie t letreehloroelhylene toluene 1,1-lrint-dlchloroethylene l.l.l-IrIfhloroelhene J,I,2-lrlehloeoellune Irlchloroethylene lrlchlorolluoro»eth»fle Vinyl chloride total *0C
tnvlronaenlel Heeturenentt
JIIH (41 JMU 1 ' «nl
l»J . nenwiwnt ';:H:
610
» 9,900
26 I
M
10
3.300 <1.000 HO <6110
39.000 2.800
<600 NO <60
<60 40.<100 HO 130
30,000 75,000 31,000
<S0 360 80
<50 13.<100 HO . <50
<250101 <50
<50 zi,<ioo in 220
<260 HO <60
<50 96.<100 HO <600
29.000 6I.U00 It,450
92 n.000 8/.000
I// 699
116.962
Held letrectt (Retults I* PPh) <600 HO <40
2-Chlorophenol HO . 15.<500 HO 13,<40
2,4-01chlorophenol 9 HO <600 HO <40
2.4-0lnelhylphenol <5.000 HO <40
4.6-0lnltro-«-cre*ol <6.000 no <40
2,4-Oleltrephenol <600 hi <40
2-Hltrophenol 110 in <600 HO <40
4-Hltrophenol 110 <600 HO <40
p-CI»loro-«-cre»ol
Hadlan Cot p.'" Had I an C»M» t 'ill) l'01
r | IcIJ lib At IJ t iUic t t (cont 'd )
Pentaclilorophenol 11 UUU 22.000
Phenol 2,4,6-lrlchloropiienol
Baie/Neutral tatract^ IftiiultTln ppC) Acenaphthene • Acenaplitliylene Anthracene Denl.dlne Benio(a)anthracen« Bcnio(e)pyrene 3.I-BentolIuoranlhene Ben»o(i.h.l)perylene Ben»o(k)lluor«nlhene bl i (2-«* loroethoay bli(2-cliloro€tKrl )elher bl»(2-<h|oroltopropyI)elher bl»(2-«thylh«»yl)phth»'*1* A.bronophenyl phenyl ether Bulylbenryl phlhalate 2-Chloronaphlhalene
JIIUU)(M .1 2S, 19111 Sc|.t./»tl.
161 I nv I raiment a I HelimeKnU .Hill ' ' and Analytlt Icli. IBM* Harch I9U6
<SUO KU 22.UUU
<SUU KU
• <40 9.UUU
<40
S6S
<IUO KU <40
<IUU 110 S.6.<40 <IUU NU <40.
<l,0UU Nil <160
cl.OUO NU <40
cl.OUU NU <40
<IUO HI <4U
<2S0 NU <40
<IUU NU <40
<2UU NO <40
83.UUU 16,600 ..<200 Ml <160
6S.OUU Ml <40
. <IU0 Ml <40
<IU0 HO 4.0.<40 <2U0 Ml <40
TABLE 1
U30ME OTMCTEHSriCS AT
Hadlan Cm p. lUdlan Corp. I'lilJ ,*ul . I leld Su^.le l«l. Sawplt
n.../n...tr»l titrattl (COI.I-UI 6-Chlorophenyl phenyl elher , Clirywm Olbenlo(».h)*nlhracene
ISO HU I,2-Dlchlorobeniene 1.J-Ulchlorobeniene |,«-Olchlorobeniene 3,J'-Olchlorobenildlne •
2,<-0Uhlorololuen« H-Chlorololueno Olelhyl phlluUte 10
Dlnclhyl plillulale 01-n-butyl plilhalale ® 2.1-Olnllrotolueno 7.6-OlnUrotoluene 01-n-octyl plilhalale 1.2-dlphenylbydra«Ino
(it aiobeniane) fluoroanthane 1luorcne tl»*«thlorobenien« lleiacltl orobul ad I «n« lle«achloro«yclopenl»dleno lleaachloroethaae ldeno(l.l.l-<d|pyrene 100 lb" Itophorone
CO <y> 00
III* I I ItHM-IH • HlltUftMll'l
IH(') inn'1' II Ciiip.''' •»'' *"*'»»•» JT*. l'..s W """
<100 mi 440
«iou HU 440
<7su iiu 440
3/0,<400 Hll 440
<4U® m <4U I 619 190, <<00 110 1.0. <«0
<100 IW <4° S.OIO
2,903
3S0 94
<100 HO <4° 44 <4U
<100 HO <4° <100 HO <4° <100 HO <4° <100 HO <4°
-<|U0 HO <4U
<100 HO <4°
<100 Ml 440
<ZUU 110 440
<700 HU 440
<400 yu 440
<2S0 HU 440
<700 HU 4,60
TABLE 1
a»Mcmusrics »T
IU<lWii Corp. IIU) I lelil irwt'lt
(I)
octroi t.tr.cll (conl'j)
lUphlhtlene llllrobonicne l|.nllro»o<ll«etliy I . H-oltrotodt-n-propyU-loo M-nlirosodlphonylimine
PHeninlhrene
TlfUM 1,2,4-lrlcMorobeiiiene ltZ.0lt(I-ehloro«lboiy)e4l"'«e •It(thloroolhoiyJelhme
%
Bl»(thloroelhyIJelher
Bli(«hloro«tbyl)*l,,*r
< i | a - l e l r e c M o r o U l b e n i o - p -dloiln
I t2-BI j(2Chloroellio»y Jollier
fe»Ucldr»/K®* PP»I
Aldrln BIIC.AIplu BUC.IeU
IU
Hull in Corp. 1901
lib Si"4'>«
200
(?) Jim .turn II Corp. m jnu 10 J««
10.000 lo 20.000 B.000
30.000 lo 20.000
12.000
26. 1901 4i.pl .JIM-
410 .120
<200 HO <40
HO <40
HO <40
<100 HO <40'
<100 HO <40
<100 NO <40
<200 HO <40
140.000
16) tiwlronmenlll Heiturementl * * onil AiiWIII r.!9US Hinli I QUI
01.000
< 2* < 2* < 2*
<40
<40 240.000
<1.0 <1.0 <1.0
S96S
61.000
CO o> CD
TABLE 1
uaowre CHAFACrraisrics AT
IU4U« Cur .1 ' "",U"11C. V' 190) '?UJ .
field 1*U W«_
e.ultlJef/PCOi (tonl'd)
OllC.Cimi BltC.Oell* Chlordine 4.4'ODl 4.4'OOC 4,4'OOO Oleldrln Cndotul fiO-*'?'14 tndo»ulU«-l»«l* (ndotul I (n MllU. Indrln Indrlo »ldehpd« lleptechlor llepltchlor epoilde PCB-1242 PCB-I2S< PCB-1221 PCB-IZ12 P« J-1240 PCD-I260 PCB-I0I6 loxphene
3 O
ln»lroll«!n 4 ,'', HeilurwnU
Ss^Zm zLaLffli 2.2
<1.0 < 2* <10 IIU
<1.0 HO <1.0
HO <1.0 lu <1.0
HO <1.0
2-1 <1.0
2-' <1.0 no
<1.0 < 2*
<1.0 2
< 2* <1.0
2 <10
<2S no <to
<zs no <10
<25 no < to
<2S no <10 <" HU <,0
<2i "° <,0 <15 HO
<10 . in
TABLE 1
LEACHATE CHARACTERISTICS AT
Volatile llun-Prlnrlly Pol lul
""(tteiulU In ppb)
At elone 2-Uulanone Carbon disulfide 2-lle*enone 4-Helhyl -2-|ieMtanone Slyrene Vinyl acelale 0.Xylene lolal lylonev
Baie-lleulral talraclahle Hon Prlorll* Pollulanl ConponnJl — JlliiuUnn ppb) Aniline Beniolc *''*1 Bentyl alcohol 4.Cliloroanlllno Olbenmluran 2•HelhyInaphlhoIone 2-HeIl»y I phenol 4-Helhylpl»onol 2-Hllroanlllne j.Hllroanlllne e-Hltroanlllne 2,4,5-lrlchtorophenol
I. Cnrp«4' iLpl./Utl. I'lUl
b20 lUO.rSUU
<50 2 J. IWO I.JOO 1.100
<50 9,200 J.5UU
<40 4(0
29.<40 5.2.<<0
<40 2.1.<«0
too 100 . <40 <40 <40 <40
TABLE 1
uaowre cmiwctmsrics *r
VoUlKe llun-t'rI"'"* Col lul4i>( "^iL. —(niiuunr. Acetone 2-Uuliiion< Ctrbon dlsutllJe 2-lle»*none 4-Hell»yl-*-l'«"ll,,ooe
Slyrent Vinyl «<*i*t« o-Xylenc lol«l *y«e"«
B„#.lleulM» l«tr»el*bl« Hon Priority Pal lot ml tog);?''1''11 — (Heiulirin |»pU)
Anil In* Bentolc itU teniyt ilcoliot A-Clilorowllln* Dlb«nialnr*n 2-Kelliyln*l,,,llu'en' 2-H*ll«yl|',,en0' 4-H*thylpl'*n0' 2-Hltro«nllln* 3-HUro«nllln« 4-Nllrotnllln* 2t4,S-lrlcl»loropl<enol
(4) II Curp V,.l ./Oct. IW
b2U IU0.<SW»
<60 23.IW
1.100 1.100
<60 9.200 3.S00
<40 460
29,<40 S.2,<40
<40 I.I.*"
100 100 . <40 <40 <40 <40
TABLE 1
UMHAtE OBIttCIEMSriCS M
IM Ibd'ont
(oiwti'l'1""' Nrwctci * HiiiiUrin'M1"! Dissolved organic carbon pll total suspended solids 000 COO AmMinU-nUrayeii UN phosphorous phosphate total dissolved solids total volatile suspended *»••«•* Vol it Ik dissolved solids Conductivity Oil and jr«»" total organic carbon Chlorides Nitrates Alkalinity Ha-'"" " CatO,
041 6.) to
4.8 240
(nvlrnm>'»tal Heasui evn'nls anil Analysis March I'J"*
4.1 SK"' 1.119 2,020
bS.S bl. 4
(b|
O.lt 1,414
144 490
1,900 »4<u/cn 1.11
1IB
121 100
.01
.» nerforued by COH In March 1905 Indicated l.acb.le
H U l t S
u,. <«..» .. '• -C-4». C—tllt Of dr«-i upon receipt U LLorUory.
.... - - -*- - - '•••'•** -(•ployed.
. ii - "worst eese"l *r* ,»d,c*led-Highest eelue (I.e.. "®r»l detection Italt
l" |,|-dlcMoroetlu«e. .
«.• r ft Inn well MM »l conclusion of 21-hour P--P Uil. Col lotted froei production well m «
. Ilul Delected „, j,. b. uncert.ln .1 . *••>'""" """" . „ '•«•»»-
• III..Let I »ol»e represents the «»*heo» outs Id* of coololwxol syslete. . Hey D. I- d«. to ..tended holding tin. •«
Chemical Concentration*
Volatile Organics:
* Benzene * 1,2-Dichloroethane * Methylene Chloride * Toluene
BaBe/Neutral Extracts: * Bis(2-chloroethyl)ether
Acid Extracts: * Phenol
Metals: * Chromium * Nickel * Lead * Mercury * Selenium * Arsenic * Silver
29 »000ppb 75,459ppb 61,000ppb 87,OOOppb
83 r000ppb
22 r OOOppb
51.Oppmt 0.70ppmf 0.92ppmt 0.13ppm 0.21ppm 0.087ppmt O.OBOppmf
5.1ppm 0.30ppm 0.12ppm
,0.074ppm , 0.026ppm
Highest concentration recently reported (see Table 1)
concentration appeared in groundwater well "'""'J; " the encapsulation system and is shown here as the nignest concentration recently reported. Corresponding value was highest value appearing in wells inside the encapsulation.
TABLE 2
CONCENTRATIONS OP CHEMICALS OF CONCERN
I. No Action II. Conplete Removal III. Enhanced Containment and IV Cleanup:
Disposal A. Leachate
1. 2. 3. 4.
Surfaje Water (i.e.. Chestnut Branch) Reinjection to containment system Local POTW Privately-owned Treatment Facility
B. Sludge 1. Privately-owned Treat
ment, Storage and Disposal Facility
2. Local POTW C. Contaminated Soil
1. Privately-cwned Treatment, Storage and Disposal Facility
Leachate Collection
A. Purp leachate from containment system at a rate above the seepage rate until the system is enptied.
B. Pump leachate from the contaiiment system at a rate equivalent to the natural seepage rate so as to maintain a static leachate level.
Punp leachate from the containment system at a rate that exceeds the natural seepage rate; reinject treatment leachate or "clean" water to maintain a static head condition and flush out the contamination. Punp leachate from the .containment system to empty the system. Allow the syston to refill and then empty the system again so that the encapsulated soil is naturally flushed.
leachate Treatment
A. Physical/Chemical Technologies 1. Activated carbon adsorption 2. Air stripping packed colum 3. Reverse osnosis 4. Wet air oxidation 5. Incineration 6. Resin adsorbents 7. Filtiration 8. Precipitation, flocculation,
sedimentation 9. VerTech
B. Biological Treatment Technologies 1. Activated sludge (PACT Process) 2. Rotating biological contractor 3. Anaerobic treatment 4. Aerobic fluidized bed
C. In-Situ Treatment 1. Bioreclamation
TABLE 3
CO CANDIDATE REMEDIAL TECHNOIXCIES
I. No Action II. Complete Removal III. Enhanced Containment and IV. Cleanup:
Disposal A. Leachate
1. Surface water (i.e. Chestnut Branch)
2. Re injection to containment system
Leachate Collection Pump leachate from the Upper Cohansey until elevation 100' MSL is reached (i.e.* top of the Lower Cohansey). Then, either let the system seek its steady-state elevation of 107' MSL or incorporate one of two punping schemes: (1) continuously punp the Upper Cohansey at a rate of 1 to 2 gpm after it is dewatered to maintain water levels inside the containment below water levels outside the containment, or (2) if exterior water levels rise due to snow-melt or precipitation, punp the Upper Cohansey down to 100' MSL after it recharges back to the level where hydraulic gradients tend be outward.
Leachate Treatment A. Physical/Chemical Technologies
1. Activated carbon adsorption 2. Air stripping packed coltam 3. Filtration 4. Precipitation
TABLE 4 SURVIVING CANDIDATE REMEDIAL TECHNOLOGIES
B. Sludge 1. privately-owned
treatment, storage and disposal facility
C. Soil 1. Privately-owned treatment# storage# and disposal facility
B. Pump leachate from containment system at a rate that exceeds the natural seepage rate; reinject treated leachate or "clean" water to maintain a static head condition and flush out the contamination.
C. Punp the Kirkwood Sand to contain/collect contaminated seepage from the overlying encapsulation system.
B. Biological Treatment Technologies t. Activated Sludge (PACT process)
C. In-situ Treatment Done
(Continued)
SURVIVING CANDIDATE REMEDIAL TECHNOLOGIES
Alternative 1
Alternative 2
Atlernative 3
Alternative 4
Alternative 5
Alternative 6
Alternative 7 Alternative 8a
Alternative 8b
Complete Removal No action but pump Kirkwood Sands (Enhanced Containment) Dewater the Encapsulation System (Enhanced Containment) Dewater the Encapsulation System and pump the Kirkwood Sands (Enhanced Containment) Flush the Encapsulation System (Cleanup) Flush the Encapsulation System and pump the Kirkwood Sands (Cleanup) No Action Flush the Encapsulation System with a batch-type process and pump the Kirkwood Sands (Cleanup) Flush the Encapsulation System with a batch-type process (Cleanup)
TABLE 5
CANDIDATE REMEDIAL ALTERNATIVES g7g
Parameter GCUA Limitation* (ppm)t
Ammonia Arsenic BOD** Cadmium Chromium COD Copper Cyanide Iron Lead Manganese Mercury Nickel pH
Phenol Silver Zinc Suspended Solids
Total Solids
Oil and Grease Total Dissolved Solids
100
0 . 1
300 0.5 2.5 600
1 . 8
0.23 5.0 0.3 .10.0
0 . 0 1
1 . 8
6.5 - 9.0 range
0.05 0.5
1 . 8
300
1300 100
1000
* Concentration based on 24-hour composite t Limitation in ppm except where noted
TABLE 6
GCUA DISCHARGE LIMITATIONS 379
Pollutant
Cadmium Chromium, Hex. Copper Cyanide Iron Lead Mercury Nickel Silver Zinc Benzene 1,2,4, Trichlorobenzene 1.1 Dichloroethane 1.2 Dichloroethane 1,1 Dichloroethylene
Ethylbenzene Methylene Chloride Trichloroethylene Tetrachloroethylene
Trichloroflouromethane
FW at 0.0576 MGD (40 qpml Flow (mq/1)
0.00013 0.0032 0.063 0.039
0.0084 0.0000064 0.63 0.0013 0.53 59.4 2.80
224 130 358.5 123.2 504 9.41
123.2
FW at 0.0792 MGD (55 gpm) Flow (mq/1)
0 . 0 0 0 1 0
0.0024 0.046 0.029
0.0061
0.0000046 0.46 0.00098 0.38 43.2 2.04
163 94.5 260.8
89.6
366.7
6.84
89.6
TABLE 7
DRAFT EFFLUENT LIMITATIONS FOR CRITICAL TOXIC POLLUTANTS
IMMUaa
teflMa
llMWIrn la laaaiai.. •an* ..KM, »• *
Ml M**lf *ltm I* m M •• ^•Mt Ita *M— 9$ fQCt »• t**
l«w*-tellMSt , I.Ill *M ».»» alM IIHTMllM $• ••••• *••• "* ***_ |M, f«4!•*•• tM 1 1 *•
.Mara..!.. * I- I—— 0-..I-•"•—4 t_ a< l——a —'• a—*. **"* CMlaHaaali la —•• t-"-
awMM aalH aaa• ta- aa, M» al aaawit •— . aa-laaia racial M* alTM •*»»•••«•• ••••
(M M(«liM *1 •M Aall**
*III t«4 I* !• «l •* , ,..u •» I.loa i~"»
•If* MI«M<I«* I a* • 41 I* •• »•* «• «•*-••• W*'- fllMMt. ItH '* H—* MW •• »•*—• Mil*# 4, NMIMW "» ***»#••• *• 4MNTN 1» tBj f r aiM MM —M— •#
ll.n Mw»« «r»» • flail, MMMt •• •Mr* Ml* IIM pa#**fl*Mi mm* MM, •** MIITNltM MM m» Mfi«« »»* M* !••• IM
Ml it |r«« n — allalla al L.,.1 Ml... l-~" - —• Mill**, *Mf# - . . . •—. M|| •M IfMlt lIMT la'Mta —,,i
'".1 —— — Ml pr«Mllllf KM, taaa*. H •**!«*• l»«^ |«r «!««• «•— ' ,fM II.I «• IM M«H. |Ml al IM Mfl^ Mil* l| Milt*
SalM ikM MW—» M !••• ,W »•»• ^ llMI I, 4 IM la •» ** *'** _
—»• *7 XZT IMIIIIaa Mlaa. ***' • . »„,Mlr.aMl-|«f <1 MM Mwrfai 1 ' 1
IMlMN I'M M •Mil* IIMMWf |iMl, tolMf I* M • »M Ml*** llM JlMI
laltf tm» Altara** lit* l,)iMl, m ilr«t *f «MIM •»**> •III IfMllllM •Ml«, VIM fMlV# IM«IN - • MWMI l*»*M |r« m mlla "Ml* •«! fiaai, Waif la«afar •»«* M l a T M l l t a a 1 * 4
Qnatviai *••• •MT«M »r«MM -CVl'if MM* IMP*, llM *1 la l«Mr«a I* (III VWMllM,
IMm imlti Mr •lialla fliaial *• I Wit a Ir« iv* I* f** —aaaaillla* iva Mt M M *Mia aim m
TABLB 8
SUMMARY OP EVALUATION OP ALTERNATIVES
UiafaaMM €•••••• •* m* • t OMI« IxwmUH* »•••• «•* »«• IN
,MC «M I ••
. -,- — man ••
al tM OTa* 6a»«M*a» II.I. s—~* r«-«(wl|, •«»"* '• |p|«l«9 Nrt, ir«M la »i«"» Mil layMl'lM •MMIUI. OTra »a**aMa IM« AIIMMIM I MMM •• •I IHIT* llrtaMi taOTa
iMlam* lalaaWllHf ImII* MM>«. «M* »MM« mMM I.iikM •M*. I* «W«I« •« M*I« •• halMM« IMP Mf
MlltP «Mk tM OTP t«a*«a» ai m *»••»
|al*M
IMII H *••• CLOTM "
»M M«OT I* VOTPt . >»«r «OT tl«aa », I OT • |lr«l (Mint OT Mil* WtM< •»** IvPtlllM mMm. all* raaaMa MMll^ •I (Ma MiMOTf fMMMI »'OT OT OT «»»• irwMl 9«OT». tlMf •• aa a #• «lt» M»MMM«M J M* •
•Irk
ft »
|a»M«
I II »N iMl l«OTMl CMMIOT*' 4MOT-mIM MoT OT OTP MM** ot»» •IMMIM,
, ).]<• •» „ «. tIMrl ll«> «• •It*. •• •• X It. !••• •*
t* M XMf cxXltMM M MM tax* •• II-1*1 Iwll •*• liaMilt* *• !••• WIMIXI '• •»
HIIMalll** •«• ** I* M •* CtaMll •tat *• ••I""*'*" •Ml* *r* "H» i «*lll*»"«H MIWI-I X n* mM i* *•••<•••••* ,1*1* «W """• *. M MM IIM»-h« II *MM«IM. |M llllll.ll I* MOT! «*" |*M| Q*l.l**l
III* t»M UMT* •ill** I » M*H* VMh *|l* III**"-* I. ). I M * • • W « 1*1* *• ilHmlU I.
P» 1mm I* *H*^I •I MM* *• """ •I *MlMlMllM.
ImIIMI**! MMIIM *M*IM I* *l|lt* **Ml •• IMMU MOT IM OT M'taOT, pototMOT ••••"» M MlOTlt mot a pOTll* •lOTtM* OT • * t OT 4.
I ta|«4*OT |OTlH «OT »ot«H ta 4I4OTOT at MOT »raa*OT !—»•»* a* OT MMlta MMOT* MM* OT'*OT OT OTOT. »» -• OT OT aaaw*a*ta , MOTOTIM »a OT paaila »Iot ot
• fiaaft OTa iMMMlalOT OT 4OT OT airuMi
J.ftl 999 f.' riaaMa*. aa •• »ot lOTaa OT OT ItOTl alOT. la a* OTOTOT IIIMOTIOT '
OTt la* OTla ta OT ot aitaatlaa OTa iMMa «OT« MOT aaOTtttaaa H OTM *OT« •• H* OTI MM* OT ra-MMM»» OTla IWI-OT» '• M*AA
fatar M* MOTr* __ OTOT I OT aaalOT c7***l** M* *"• M*MT*. _ .IM *• l*|MllM "" M.-I- ...I MMIM.MKM M '• •WIOTOT at OT # ava*OT la aOTOTIaatatf f|M« MtOT raaa*ta aa OT aaa*aa» Maa*» lOT *« aMaatlaa*
- ot* IIMOTM *• OTataaaOT Mm* OT IM* OTMI«m»
•9
la <
OT eetNetf •» r,*Trr pfl MM ia|aa#Ma il*a OT •**•••• OT attalt* OTMOT OT aa aaaOT*OT*a ttlOT OT OTa OT»«*
TABLE 8
• • rw HWD»
Ml# talla****** 191 IW
• IIM* *ta fMHHUtl' m a ta»«a taaU m*
1,101 909 »(W
i«Mt f•»!•••• MlVHtlM la »«#•• *1 *•#«• «r l«*l«0 ta*ac«« » a«a «l «•••••*• • laa ta «H aael-rpHit Ota WIMllWW •Oft (*•»••« »• m# tiitai •IoIm tar «a*lta" flMftlaf, ta I* rdota ta I*1 l« n
t—>M Qeatafta tta*tae*talM*v
% lNl«t lltaMtl" la !•>!—-it flaaa *a«v lalraO all* N »aa<lM tm aala-Immm m4 • iafa»« |«<f MMalaO aaata talaO
la I«m a* 0 CtaVftaf -* W
r« ta
faaMlMl •lata aHta*** taa erIMtaMv a# atafvta aalta *• aiitaa
»»•»• w tattaaOafv »»•» '»i tata •* tali wnlapo taa ara aa|ar |a* taaaaatra*1 ' 0# ta allaattaa ** •talta aataaOI«V ctaltliM •• ttaaa law# a* llaarl ta Ota ralliMMtf a# fata faataaOaoi •• otar*-a*raal«at Mtafltaaala. ta* la aa* aa ta par, fta |t««H a# ptafaa* aa la lllll«| Ma aaaaaoata MNrtata 1 ••ta a«M olaaa •»#, ta •• •aaatalaf fta ta talltta ta lltaal fa ta • «a#a rallaMa •••oalaf
fata* »Ma«fH«f •ta anlM aaaf ta aaarata, lltfla ar «a otaaaa •or tatao •# aaaa lata atataf tIM ta aaiortaaa aataiaio
fata ftaa AltaaaMea I ta ta«l*a tatara, >l»a alM Mia** tlral I, J. «. 9 •.
flfa Claa» 41 M
taaairta
llriMl favln V*
laolltataal ta i««iii ta a tatalta ta ta !•••• ta*aaia iliaaaM* ta *****
Mtaraallva 9 ,
ftttapTo ta uMiolf *ta raaalr# • ,l«ta Ota aa*a«a a* la|aa*taa pa taata*aa*laa« Ota •#•«• ta 9* fra* aalta * aa a**o**a atao «ta* lOtaa taaaflaa ifMlt «a*ta
ta Ota *MM « aa* aa •«*** M*a**<* I*
Mtaaaflaao % ata V
SUMMARY OP EVALUATION OP ALTERNATIVES (Continued)
llltfMtl**
IWt II10091
CnMtl ••
ll«* »• « • Mica M«<*
*»•«**•
I.IM •• l# #•!•••• »• V"1
•lit, U • iMMwIatf. ••• Ml* II Mt I«M ««»•<(•*•* M I* •«••«•••• •Malar cvalflaM •• «N0 M«* * »IN»t N*« |k« •• Ml* MMaiatf ••
llMllk>
PIlMckltlM U t«M •»
«** rwl* •« will «r« (MMlkkl «*•»•*•• IIM «<"••!« Hk«H u •I «(!•• "*•••1 m k**'1** •'
TMt M MMiil |K«
Mt«r MM lltVHllll I (or Mkiia 0» i a* »HI II* lyMllMk 2« I* '• |k*l. •»*•••• M UfkrakllM I.
Cl«
19
(M •|r»« VI
IwlraMtkl Itfl* III*. lllwkl »• «%• **M «•
fmH M mw» •* plk(fM*«l * M ••••!!• Mill (Ml *••» M (MM, M M MMl'Mki* M M* p*IM H«* **•
imiiMHi. • • -«.*r. M. *«*• *\ HtllM Ma <••—«!— * IIM klM alaM MW. •• akM«*l*f Ma ••••« kM railllN ••• k*«a^«ll« la a^ iiavki «• V* • laliaMa
IkTMiNaa t aal ?•
TABLE
CO 00 U1 MMTSSSffS"55 STEK
figure 1 GENERAL LOCATION PLAN 333
FIGURE 2
GENERAL AREA PLAN 387
FIGURE 3
DETAILED AREA PLAN 388
FIGURE 4
FENCE INSTALLATION 339
